ML20213A327

Notice of Violations from Insps on 860211-0523.Violations Noted:Failure to Rept or Correct Condition Described in Nonconformance Rept SQNCEB8409 & Internal Procedures for SQNCEB8409 Failed to Meet Design Procedures

ML20213A327
Person / Time
Site:	05000000, Browns Ferry, Sequoyah
Issue date:	01/28/1987
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML082280209	List: ML20213A327 ML20213A393
References
50-327-86-56, 50-328-86-56, NUDOCS 8702030219
Download: ML20213A327 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Tennesset Valley Authority Docket Nos. 50-327 & 50-328 Sequoyah, Units 1 and 2 License Nos. DPR-77 & DPR-79 The Nuclear Regulatory Commission (NRC) inspections conducted during various intervals between February 11 and May 23, 1986 identified violations of NRC requirements.

In accordance with the " Generic Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986),

these violations are described below.

A.

10 CFR 50.73 requires that the holder of an operating license for a nuclear power plant shall submit a licensee event report (LER) for certain defined events within 30 days after discovery of the event. Specifically, 10 CFR 50.72 (a)(2)(v)(A) and (D) require the reporting of any event or condition that alone could have prevented the fulfillment of the safety function of systems needed to shut down the reactor and maintain it in a safe shutdown condition or to mitigate the consequences of an accident.

Such events, as defined in 50.72 (a)(2)(vi), may include discovery of one or more design or analysis inadequacy that requires reporting unless redundant equipment was operable and available to perform the required safety function.

Contrary to the above, the Tennessee Valley Authority (TVA) has not reported nor corrected a condition described in Nonconformance Report SQNCEB8409 thut pertains to these requirements. A responsible engineering manager for the Sequoyah plant was notified by copy of a letter that was received by at least August 30, 1983, that conditions found at the Watts Bar plant substantiated the existence of a situation, resulting from the initial analysis and design, where safety Class IE electrical systems were not designed or protected ar,ainst the effects of failures in Category I(L) piping (nonseismically designed). Various actions were taken at the Sequoyah plant to identify areas of concern where this problen also could occur. By March 1984, it had been determined that there were conditions at the Sequoyah plant where spray from the failure of non-seismically qualified piping could affect Class IE electrical safety equipment in the auxiliary, control, and diesel generator building. The issue was identified as a nonconformance on May 18, 1984 and was restated in the Failure Evaluation / Engineering Report, Rev. 1, dated July 13, 1984.

The Deficient Condition Evaluation indicated that the condition was not acceptable for some design loading ccmbinations or design ccnditions, but the statenent was qualified to indicate that functional impairment of the component (s) is not likely. Nevertheless, this condition was not in conformance with the design basis of the Sequoyah plant and was not reported in accordance with the requirements of 10 CFR 50.73.

In addition, no indications of studies or analyses to substantiate that redundant equipment would remain operable and available to perform the required safety function were found during the NRC inspection (Sample No.1).

This is a Severity Level IV violation (Supplement I).

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Notice cf Violaticn 2-B.

Criterion V of 10 CFR Part 50, Appendix B, requires that activities affecting quality shall be prescribed by documented instructions and that procedures and activities shall be accomplished in accordance with those documents.

Section 17.2.5 of the TVA Quality Assurance Program (Report No. TVA-TR75-1) implenients these requirements. Additionally, TVA maintains a Statcment of Policy dated May 2, 1977 governing design manuals (Guides and Standards) that indicates that failure to follow a design standard requires a followup notification to the Standards Board Chairman.

Contrary to the above, TVA failed to implement its internal procedures for SQNCEB8409 regarding notification of the Standard Board Chairman in 1984 when it was known that the Sequoyah plant failed to meet the design standards in DS-E1.3.3, " Protection of Electrical Equipment That Is Susceptible to Failure From Fluid Spray and Condensation," dated April 23,1960 (Sample 1).

This is Severity Level V violation (Supplement I).

C.

Criterion XVI of 10 CFR Part 50, Appendix B, requires that measures shall be established to ensure that conditions adverse to quality, such as deficiencies, deviations, and nonconformances, are promptly identified and corrected.

Section 17.2.16 of the TVA Quality Assurance Program (Report No. TVA-TR75-1) implements these requirements.

Contr6ry to the above:

1.

In March of 1983 TVA prepared a Failurc Evaluation / Engineering Report for SQNCE58301 concerning the fact that eight diesel generator exhaust lines in the original diesel building were not qualified for the faulted loading combination that includes the safe shutdown earthquake.

The original diesel generator building is categorized as seismic Category I and the exhaust lines are designed as TVA Class G Seismic Category I piping.

FSAR Table 3.2.2-3 defines TVA Class G piping as non-r.uclear safety class piping built to ANSI B31.10-1967, but requires Class G piping inside Category I structures be seismically supported.

The failure evaluation stated that failure of the exhaust lines wculd not inipair diesel generator function, but there were no supportable engineering facts or c.nalyses with the report. TVA took no action to provide the correct seismic designs or configuration at the i

Sequoyah plant. Consequently, TVA has allowed an adverse condition to exist for cver 3 years with the knowledge that safety systens failed to comply with their design bases (Sample 7).

This is a Severity Level IV violation (Supplement I).

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hotice of Violation 2.

In November of 1982 TVA management had information in a Failure Evaluation / Engineering Report for SQNSKP8215 and SQNSWP8222 which left an open question as to whether portions of Class B systems, such as the chemical and volume control system, the safety injection system, and the containment spray system, met these design bases.

Alternately analyzed piping could not be verified as meeting seismic requirements since the application of the analysis techniques were in question. The bases used in the justification of inaction are not sufficient.

Statements to justify continued operation and inaction, such as, "the combined 7 to 8 years operating experience of the two SQN units has demonstrated that the plant is safe for normal operation," are not appropriate to justify that the facility can withstand a design-basis event like a design seismic event when the plant design for that seismic event cannot be verified.

Consequently, TVA has allowed an adverse condition to exist for over 3-1/2 years with the knowledge that some Class B safety systems could not be verified as being in conformance with design bases (Samples 8 and 9).

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, the Tennessee Vciley Authority is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for euch violation:

(1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR TFE NUCLEAR REGULATORY COMillSSION J

ar/sl<. Taylor

.i rector 0 fice of Inspe tion and Enforcement Dated at Bethesda, l'aryland, this 28 day of January 1987.

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